The Association of Chartered Certified Accountants (ACCA) has advised that the adoption of electronic invoicing (e-invoicing) in the UK should remain voluntary for both businesses and the public sector.  

The recommendation follows a consultation by HM Revenue and Customs (HMRC) on promoting e-invoicing across the UK.  

ACCA stresses that the move should be demand-led and not detract from existing priorities such as Making Tax Digital (MTD). 

ACCA proposes a decentralised ‘four-corner model’ for any e-invoicing system, allowing for independence and flexibility without locking users into a central platform.  

Glenn Collins, Head of Policy, Technical and Strategic Engagement at ACCA, expressed concern that introducing e-invoicing might divert limited resources and risk slowing progress on MTD, especially given the investment already committed by software developers, taxpayers, and other key stakeholders. 

Collins added: “We would encourage a cautious approach when considering the capacity HMRC would have to implement new developments such as e-invoicing while HMRC reforms and areas such as MTD are at the early stages of phased implementation. In other words: concentrate on making MTD a success.” 

ACCA regional lead for policy & insights Joe Fitzsimons said: “A voluntary system of e-invoicing designed to encourage business adoption to realise key business benefits is the most productive approach. Cost benefit analysis will remain crucial as well as considering how e-invoicing can best work for business in practice.” 

Fitzsimons urged the government to examine established e-invoicing frameworks in countries where such systems are already in place and to adopt a phased rollout.  

This, he said, would help build the necessary capacity and capability while ensuring that valuable lessons are incorporated into the implementation process. 

Earlier in May 2025, the Institute of Chartered Accountants in England and Wales (ICAEW) also supported voluntary e-invoicing adoption in the UK, suggesting mandatory implementation be postponed until at least 1 January 2030.  

ICAEW highlighted international evidence of improved productivity, reduced costs, faster payment times, better cash flow, and increased tax compliance and revenues as benefits of e-invoicing. 

ICAEW noted that many countries, including EU member states, have already implemented e-invoicing mandates or frameworks.  

The organisation expressed concern that the UK’s lack of a coordinated e-invoicing policy could disadvantage its businesses and deter capital investment.